1. Overview
This document describes how CurrentClient meets SEC Rule 17a-4, the Investment Advisers Act of 1940, and FINRA Rules 3110 & 4511 recordkeeping and supervision requirements.
Audience: Compliance officers, auditors, and regulators reviewing the use of CurrentClient for compliant communications archiving.
2. Record Capture
CurrentClient automatically captures:
Text Messages (SMS/MMS) - Full message content including media files.
Metadata - Sender/recipient, date/time, message ID, delivery status.
Records are captured in real time and stored immediately in a secure archive.
3. Retention & Regulatory Compliance
Retained for a minimum of 5 years; first 2 years instantly retrievable.
Stored in AWS S3 with object versioning enabled.
Original records cannot be overwritten. Edits and deletions create a new immutable version while retaining the original.
Version history includes timestamps, user/process changes, and access to prior versions.
Aligns with SEC Rule 17a-4(f) 2022 amendments allowing version-controlled, audit-capable systems.
4. Integrity & Security
Version Control - Preserves all historical versions of a record.
Audit Logging - Tracks access, exports, and modifications.
Encryption - TLS 1.2+ in transit, AES-256 at rest.
Access Controls - Role-based permissions to restrict who can view, search, or export records.
5. Supervision & Review Tools
Searchable Archive - Search by client, keyword, date range, or record type.
Supervision Workflows - CurrentClient supports supervision by:
◦ Sending all captured messaging data to the firm’s chosen third-party archiving system for review, or
◦ Co-locating all captured messaging data into the firm’s existing email archive so their current supervision workflows apply.
Review Logs - If the firm uses CurrentClient’s direct archive export, activity logs record when reviews occur and by whom.
6. Retrieval for Regulatory Requests
Export Capabilities - CSV, PDF, and media formats for regulators.
Time-Stamped Certification - Confirms record authenticity.
No Gaps in Records - Continuous capture with no user-side deletion.
7. Advisor Responsibilities
Advisors must:
Maintain a written communications retention and supervision policy.
Periodically review communications for compliance issues.
Ensure all business messaging takes place through CurrentClient or other approved channels.
8. CurrentClient Commitment
CurrentClient is committed to:
Providing advisors with a compliant, secure messaging archive.
Maintaining system compliance with SEC/FINRA rules.
Supporting retrieval requests during regulatory audits.